https://www.taxtmi.com/caselaws?id=310755 The ITAT Delhi remanded the transfer pricing addition under section 92CA(3) back to the TPO following the Delhi HC's direction to apply TNMM at entity level. The HC had previously rejected the aggregation approach under TNMM for benchmarking international transactions relating to royalty and technical services, following the precedent in Magneti Marelli case. The TPO was directed to reconsider the MAM selection between TNMM and CUP methods. The assessee's appeal was allowed for statistical purposes with the matter being remitted for fresh consideration by AO/TPO. en-us Fri, 16 Jun 2017 00:00:00 +0530 Wed, 22 Nov 2023 11:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=310755 The ITAT Delhi remanded the transfer pricing addition under section 92CA(3) back to the TPO following the Delhi HC's direction to apply TNMM at entity level. The HC had previously rejected the aggregation approach under TNMM for benchmarking international transactions relating to royalty and technical services, following the precedent in Magneti Marelli case. The TPO was directed to reconsider the MAM selection between TNMM and CUP methods. The assessee's appeal was allowed for statistical purposes with the matter being remitted for fresh consideration by AO/TPO. Case-Laws Income Tax Fri, 16 Jun 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=310755